Which Products Require a Children’s Product Certificate (CPC)?

Creating a Children’s Product Certificate (CPC) is mandatory if your product is determined to be a children’s product and subject to one or more children’s product safety rules. In this guide, we explain how you can assess if this is the case, while also providing examples of products that require a Children’s Product Certificate in the United States.

How to determine if your product requires a Children’s Product Certificate

This process involves determining if your product is defined as a children’s product and identifying one or more applicable children’s product safety rules.

Step 1: Determine if your product is a children’s product

Children’s products are generally products that are primarily intended for children aged 12 years or younger. However, manufacturers and importers cannot arbitrarily decide if this is the case. Instead, children’s products as classified as such based on the following criteria:

1. The intended use of the product

2. If the product is presented as suitable for children (this takes packaging and marketing into account)

3. If the product is generally deemed to be suitable for children

4. CPSC age group classification guidelines (which exist for certain product categories)

In short, you cannot decide that a teddy bear is not a children’s product for the sake of evading the requirement to create a Children’s Product Certificate.

However, if you deem that your product is not a children’s product, then you may still need to issue a General Certificate of Conformity.

Step 2: Identify general children’s product safety rules

Children’s product safety rules determine if you need a CPC in the first place. While some of these only apply to certain products, there are rules that are generally applicable to all children’s products or broad categories of products.

Here are some examples of general children’s product safety rules:

Toys

Part 1250 – Safety Standard Mandating ASTM F963 for Toys

Small parts

Part 1501 – Method for Identifying Toys and Other Articles Intended for Use by Children Under 3 Years of Age Which Present Choking, Aspiration, or Ingestion Hazards Because of Small Parts

Substances

Part 1303 – Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint

Part 1307 – Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates

Step 3: Identify specific children’s product safety rules

Some products are subject to specific children’s product safety rules. Here are some examples:

Part 1513 – Requirements for Bunk Beds

Part 1239 – Safety Standard for Gates and Enclosures

Part 1231 – Safety Standard for High Chairs

Part 1233 – Safety Standard for Portable Hook-On Chairs

Part 1224 – Safety Standard for Portable Bed Rails

Part 1217 – Safety Standard for Toddler Beds

List of Products Requiring a Children’s Product Certificate

Here is an overview of some key product categories that require a Children’s Product Certificate.

Toys

Creating a Children’s Product Certificate is mandatory for all toys for children between the ages of 0 to 12. This is because Part 1250 applies to toys as a category.

Further, electronic toys must comply with Part 1505, which also mandates the creation of a CPC.

Children’s clothing

Certain types of children’s clothing are covered by rules for which Children’s Product Certificates are required:

• Children’s sleepwear
• Wearing apparel

Note that testing exemptions exist for certain types of wearing apparel for adults. However, the requirments are stricter when it comes to wearing apparel for children.

Children’s furniture

Here are examples of children’s furniture that require a Children’s Product Certificate:

• Bassinets
• Cradles
• Cribs
• Clothing storage units
• Bunk beds
• Portable hook-on chairs
• Portable bed rails
• Baby beds

Other children’s products

Here are some other children’s products that are covered by specific product safety rules:

• Children’s bicycles
• Children’s bicycle helmets
• Baby carriers
• Gates
• Play yards
• Baby bath tubs
• Swings
• Walkers
• Nursing pillows
• Pacifiers
• Rattels

Some rules cover children’s products containing specific components:

• Children’s products containing button cell batteries
• Children’s products containing magnets

You can find the full list of products that require a CPC on the CPSC website.

Do I need a Children’s Product Certificate if there are no rules for my product?

Yes, you still need a Children’s Product Certificate, as you must demonstrate compliance with rules that cover children’s products as a group. For example, lead restrictions apply to children’s products in general.

As such, creating a Children’s Product Certificate is not only a requirement for products that are covered by product safety rules.

Which products do not require a Children’s Product Certificate?

Products that are not defined as children’s products do not need a Children’s Product Certificate. That said, such products can be subject to other certification and documentation requirements in the United States.

For which products does Amazon require Children’s Product Certificates?

Amazon requires Children’s Product Certificates for products that are covered by CPSC rules, which in turn mandate it. As such, Amazon does not extend the Children’s Product Certificate requirement to other products or exempt products that require CPCs.

In some cases, it can be difficult to determine if a product is a children’s product and therefore requires a CPC. In these situations, the best course of action is to examine the age group classification guidelines from the U.S. Consumer Product Safety Commission.

What do I need to do if a Children’s Product Certificate is required for my product?

If a Children’s Product Certificate is required for your product, then you need to contact a CPSC-accepted testing company to arrange testing according to all applicable product safety rules.

Once this is done, you must create the Children’s Product Certificates based on the test report.